Initial Notifications Concerning Emissions Inventories for the Natural Gas Industry

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Gladys Powell
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1 Initial Notifications Concerning Emissions Inventories for the Natural Gas Industry Marcellus Shale Coalition Meeting December 5, 2011 Joyce E. Epps Director Bureau of Air Quality Pennsylvania Department of Environmental Protection

2 Emissions Inventory Overview There are significant natural gas exploration and extraction activities occurring in the Pennsylvania Marcellus Shale formation and other formations in Pennsylvania. In December 2011, the Pennsylvania Department of Environmental Protection (DEP) will issue initial notifications requiring the reporting of information including emissions data for the natural gas industry. The initial notifications, authorized under section 4(3) of the Pennsylvania Air Pollution Control Act (35 P.S. Section 4004(3)) and 25 Pa. Code Section (relating to reporting), will allow the DEP to develop its first emissions inventory for the natural gas industry. 2

3 Emissions Inventory Overview Emission inventories allow the DEP to quantify emissions from air contamination sources in order to: compile an accurate inventory of air contaminant emissions for air quality assessments and planning activities; develop State Implementation Plan revisions for the attainment and maintenance of national ambient air quality standards including ozone, fine particulate matter, lead, nitrogen dioxide and sulfur dioxide standards; and identify available or potential emission offsets. Emission inventories also provide information to support permit reviews, dispersion modeling and risk assessments. 3

4 Emissions Inventory Overview The DEP is required to submit complete comprehensive emissions inventories to the U.S. Environmental Protection Agency (EPA) every three years in accordance 40 CFR Part 51, Subpart A (relating to air emissions reporting requirements). The emissions inventories for calendar year 2011 emissions must be submitted to the EPA by December 31, The comprehensive emissions inventories will include point sources (large stationary sources including electric generating units, refineries, manufacturing plants), area sources (small stationary sources including, autobody shops, surface coating, degreasing operations, dry cleaners, gas stations), mobile sources (including on-road and non-road sources), and biogenic source (non-fossil fueled sources including oak, pine, maple). 4

5 Emissions Reporting and Recordkeeping Overview In accordance with 25 Pa. Code Section 135.3(a), the initial source report for calendar year 2011 emissions will be due to DEP no later than March 1, 2012, and each year thereafter. An extension of time may be granted beyond the March 1 submittal date for a reasonable cause. The reports must contain sufficient information to allow the DEP to complete the inventory for the natural gas industry by December The reports must be submitted to DEP using a format specified by the department. 5

6 Emissions Reporting and Recordkeeping Overview Records including records of production, fuel usage, maintenance of production or pollution control equipment must be maintained to demonstrate compliance with the reporting requirements. DEP may also request other information needed to identify and quantify actual and potential air contaminant emissions. The records must be provided to DEP upon request. 6

7 What Emissions Inventory Data is Required for the Natural Gas Industry? Emission estimates for both criteria and hazardous air pollutants should be reported along with production and hours of operation data used to calculate these emissions. The owners/operators will submit the data to DEP using a secure Internet-based reporting system. The Department considered natural gas emissions reporting requirements in the States of Colorado, Texas and Wyoming. 7

8 Air Contaminants Subject to Chapter 135 Reporting Requirements Criteria pollutant and precursor emissions Carbon Monoxide Lead Nitrogen Dioxide Ozone precursors (Oxides of Nitrogen and volatile organic compounds) Particulate Matter (including PM2.5 and PM-10) Sulfur dioxide Hazardous Air Pollutants (HAP) including the following: Benzene Ethylbenzene Formaldehyde N-hexane Toluene 2,2,4-trimethylpentane; xylene Total HAPs 8

9 Air Contamination Sources Subject to Chapter 135 Reporting Requirements Sources and activities subject to the emissions reporting requirements will include the following: Dehydration units Drill rigs Fugitives (connectors, flanges, pump lines, pump seals, valves, etc.) Heaters Pneumatic devices Stationary engines Tanks/Pressurized Vessels/Impoundments Venting & blow downs Wellheads Well completions/work overs 9

10 Emissions Data Requirements Engines: engine model, fuel type, fuel quantity, fuel % sulfur, horsepower, % average load, hours of operation, emission factor basis, type of control. Heaters: size (MMBtu/hr), hours of operation. Tanks: Gas and/or water produced (barrels), number of condensate and water tanks, impoundments, hours of operation, controls and control operation. Dehydrators: gas processed, design rating, actual operating hours, lean glycol circulation rate, controls and control operation. 10

11 Emissions Data Requirements Pumps: gas processed, condensate processed, number of pumps, hours operated, controls and control operation. Venting: number of blowdowns, average blowdown rate, average blowdown length, controls and control operation. Drill Rigs: drill dates, total hours, fuel usage. Completions: start and end date, total hours. Fugitives: number of connectors, flanges, open ended lines, pump seals, valves. 11

12 How Will The Data Be Submitted? The DEP is developing a Shale Air Emissions Data Management System. This system will be an Excel spreadsheet solution for the submission of the data. The Oil and Gas Reporting-Electronic (OGRE) System will be modified to accept the data electronically. Owners/operators will access and log in to OGRE. The system will display well sites for each owner/ operator. There will be a download button to create the appropriate spreadsheets. These spreadsheets will have location and identification information preloaded. 12

13 How Will The Data Be Submitted? DEP anticipates that the Shale Air Emissions Data Management System will be available in February Owners/operators will be notified when completed spreadsheets can be uploaded to the system. DEP will also provide compliance assistance and training in February

14 Emission Inventory Contact Questions on the inventory may be directed to: Michael Rudawski

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